## Facts

- Ladell Henderson, an Illinois prisoner, was convicted of murder and attempted murder arising from a February 1984 shooting in a Chicago apartment.
- Mona Chavez identified Henderson—whom she knew from the neighborhood—as the shooter; her uncle, Dennis Leonard, was killed, and Chavez survived multiple gunshot wounds.
- After arrest, police advised Henderson of his Miranda rights at the scene and again at the station; Henderson initially declined to give a statement.
- Later the same day, after renewed Miranda warnings by an assistant state’s attorney, Henderson gave a detailed written confession that he read and signed.
- At trial, Henderson argued his intellectual limitations prevented a voluntary, knowing, and intelligent Miranda waiver.
- Henderson sought to introduce evidence that Chavez used narcotics to impeach her credibility; the trial court excluded the proffer.
- The Illinois appellate court vacated a conspiracy conviction but affirmed the murder and attempted murder convictions and sentences.
- Henderson filed a federal habeas petition under 28 U.S.C. § 2254 challenging (1) admission of his confession and (2) exclusion of the drug-use evidence; the district court denied relief.

## Issues

1. Whether Henderson’s confession was admitted in violation of the Fifth Amendment because his Miranda waiver was not voluntary, knowing, and intelligent given his intellectual limitations and alleged confusion about the prosecutor’s role.
2. Whether excluding evidence of the complaining witness’s narcotics use violated the Sixth Amendment rights to confrontation and to present a defense.

## Decision

- The Seventh Circuit affirmed the denial of habeas relief.
- The court held the state courts’ findings supported a valid Miranda waiver and voluntary confession under the totality of the circumstances.
- The court held excluding generalized drug-use impeachment did not violate the Confrontation Clause and did not render the trial fundamentally unfair.
- The court noted that the petition failed under both pre-AEDPA and AEDPA-era standards of habeas review.

## Legal Principles

- A Miranda waiver is assessed under the totality of the circumstances; limited intellectual functioning is relevant but does not by itself invalidate a waiver.
- On federal habeas review, state-court factual findings (including credibility determinations about warnings, understanding, and voluntariness) are entitled to substantial deference and are not displaced without a strong showing to the contrary.
- The Sixth Amendment does not require admission of all impeachment evidence; trial courts may exclude marginally relevant or improper character evidence, especially where the defendant retains other meaningful avenues for cross-examination.
- Federal habeas relief is not available for ordinary state evidentiary errors unless the ruling violates a specific constitutional right or makes the trial fundamentally unfair.

## Conclusion

The Seventh Circuit denied § 2254 relief because the record supported the state courts’ determination that Henderson knowingly and voluntarily waived Miranda rights and because excluding generalized evidence of the victim’s drug use was a permissible limitation on impeachment that did not violate the Sixth Amendment.


Henderson v. DeTella, 97 F.3d 942 (7th Cir. 1996)